Aaron L. Brody

Industry certification programs for individuals and processing facilities have existed for some time, and recently, we have cautiously waded into the realm of close examination of food-package converting plants. Converting plants manufacture package materials and structures for eventual application in food plants to contain, protect, and help preserve food and beverage products. Among the types of package converters most directly involved in food packaging are those that produce flexible films, pouches, plastic bottles, paperboard cartons, glass bottles and jars, and steel and aluminum cans. Officially, all such plants in the United States are subject to regulation when the materials and structures are ultimately in direct contact with food and/or beverages. And many large food/beverage processors/packagers often compel special quality assurance measures at such plants.

This colorful product for kids is produced at Sonoco’s flexible packaging facility in Terrebonne, Quebec, Canada, one of the nine converting plants where pilot operations were conducted for the new Canadian packaging standards program.

Converting Operations Are Not Food Plants
For many food/beverage processors/packagers, however, the sheer number of different primary packages and their different suppliers render this oversight a mammoth task. Thus, much depends on the integrity and internal controls of the converter/ vendor. That so few incidents have occurred is a tribute to the openly cooperative efforts, and sometime contractual obligations, of the two parties. It also helps that American Institute of Baking and regulatory officials are not infrequently visiting to confirm that the materials and structures are safe from microbiological, chemical, and physical perspectives.

But incidents have occurred that are within the control of converting plants. These include contaminants in empty bottles and cans delivered to packagers with no empty-package cleaning capabilities; occasional microbiological spots on the interiors of flexible packages; insufficient heat sealant on the flexible material interior surface; mislabeling; and even wrong color on a design. Although infrequent, such incidents have happened and will undoubtedly occur again. Concern can be a powerful driver.

One Solution
From the Packaging Association of Canada (PAC) comes a new initiative called PACsecure—Safe Packaging for Food and Beverage Packaging. This program was detailed by PAC head Scott Wilson ([email protected]) at the October conference on "Hot Topics in Food Packaging–Barriers with Brains" organized by Guelph Food Technology Centre (www.gftc.ca).

The PACsecure program is a food safety initiative for package materials that have direct contact with foods, i.e., primary packaging. It is not aimed at secondary or distribution packaging—yet. It is a standard that includes package materials that are to be manufactured to a recognized standard based on HACCP principles. Although not yet industry-wide in Canada—the program is still too new—PACsecure organizers are hoping for widespread acceptance and application, particularly for materials and structures destined for export to the U.S. The program employs recognized Canadian audit and certification capabilities and proposes high industry and public awareness to spark universal acceptance.

The program began in 2002 with formation of a PAC enabling committee and a draft prerequisite project and HACCP plan for flexible package materials—usually delivered as roll stock. A pilot project was begun in 2004 to validate the draft standards. In 2005, the group developed pilot draft HACCP standards for rigid plastic and paper-based package materials/structures, with first publication in 2007. Only this year has a company, Jones Packaging, a Canadian converter of paperboard folding cartons, labels, and shrink film sleeves, had its two plants audited and certified to PAC standards.

Standards Development
More than 80 companies participated on the working committees to establish standards for each specific converting operation. Cross-functional teams represented food/ beverage packagers, raw material suppliers, converters from various elements, Canadian government officials, HACCP experts, and, of course, packaging industry experts. Consensus decision-making dictated the process.

The list of organizations that participated includes the following, along with many others: Alcan Packaging, Ball Packaging Products, the Brewers Association of Canada, the Canadian Food Inspection Agency, Coca-Cola, General Mills Canada, Guelph Food Technology Centre, Kraft Foods Global, Loblaw Brands, McCain Foods, Nestlé, Parmalat Canada, Sonoco, and TetraPak Canada.

Pilot operations were conducted at nine converting plants: Cousins-Currie, two plants—blow molding of plastic bottles; Graphic Packaging—paperboard and film laminating; Jones Packaging, two plants—paperboard cartons; Chantler Packaging—flexible packaging; Norampac—corrugated fiberboard cases; Plasticap—injection-molded rigid plastics; and Sonoco—flexible packaging.

Prerequisite Program
Before HACCP can be implemented, a good prerequisite program should be in place to address the majority of food safety concerns—effectively a sanitation audit of the converting plant to identify concerns that might affect the safety of food to be packaged downstream.

Areas for inclusion in the audit can be broken out as follows:
• Premises—building exterior; building interior—design, construction, maintenance, lighting, ventilation, waste disposal, employee and sanitation facilities, water, steam, etc.

• Transportation and storage—carrier quality, temperature controls, and storage.

• Equipment—appropriateness of design and engineering.

• Sanitation and pest control—good housekeeping.

• Personnel—training; hygiene and health requirements.

• Recall and traceability.

PAC HACCP Standards
The following sequence is the recommended approach for the development of an acceptable PAC HACCP program for a converter. These directions, of course, are familiar to food processors and include the steps that follow:
• Assemble a HACCP team.

• Describe the product.

• Identify the intended use—application for food packaging.

• Construct a process flow diagram and plant schematic for the product.

• Construct on-site verification of the flow diagram and plan schematic.

• Identify hazards. List preventive measures to control them (HACCP Principle 1.)

• Determine critical control points (CCPs) (HACCP Principle 2).

• Establish limits at each critical control point (HACCP Principle 3).

• Establish procedures to monitor critical control points (HACCP Principle 4).

• Establish corrective action to be taken in case of deviations (HACCP Principle 5).

• Establish procedures to verify systems are functioning correctly (HACCP Principle 6).

• Establish effective record keeping (HACCP Principle 7.)

A PAC HACCP tool kit provided to companies wishing to institute PACsecure is comprised of two key components: the prerequisite program—common good manufacturing practices (GMPs) for converting industries and HACCP standards for specific converting operations including flexible and rigid plastic packaging; paper and paperboard; metal; and glass.

PAC provides training materials to assist users in implementation, but, of course, there is a price for this resource.

A Value Proposition
PAC contends—and probably correctly—that the cost (discounted when one of the authorized organizations performs the work) of implementation is really an investment and cites a long list of benefits it provides. First, adoption of the PACsecure program results in improved customer satisfaction; improved converting operations will improve quality. In addition, food processors/packagers are insisting on some sort of internal regulation of safety by their suppliers. Larger customer companies want HACCP compliance. For Canadians, such a program would mean increased export opportunities because HACCP is internationally recognized and accepted by food processor/packagers that would be purchasing package materials and structures.

It also provides the ability to standardize converting processes and products across multiple plants, which is always a contentious issue when package materials are received from different operations. Such a system leads to reduction in rejects, waste, and scrap as well as a reduction in employee absenteeism thanks to the improved hygiene requirements. Other potential benefits include a reduction in business risk in areas including product recalls necessitated by food safety issues and a reduction in contaminants such as allergens and metal and glass fragments.

Finally, PACsecure provides for the identification of continuous improvement opportunities to enhance operations because of an ongoing examination of critical unit operations.

Certification Protocols
Unfortunately for converters, at this time, they cannot certify themselves and receive an official authorization. (In the U.S., food companies may indeed self-certify HACCP programs, but official certification for packaging converting plants is not yet in place.

PAC has established partnerships with firms that specialize in auditing and certification for the likes of ISO or industry standards. To date, only five organizations are authorized to audit and certify. They include: QMI-SAI Global—Ontario (www.qmi-saiglobal.com); Guelph Food Technology Centre; Kasar Canada; Centric Source (British Columbia); and Jacinthe Lefebvre (Quebec).

Until recently, packaging purchases were treated as just another nuisance by too many food scientists and technologists. The rash of visible issues related to package deficiencies has led to increasing pressure to more carefully acquire and apply package materials and structures. Routine food/beverage packager quality measurements are hardly sufficient to identify either continuing or transient problems. For example, incoming inspection could not be expected to detect minute quantities of volatile organic solvents appearing in rolls of flexible packaging imported from the Far East. What sampling tests could sense the presence of glass fragments in an incoming shipment? Or what about dirt on empty bottles accidentally exposed to an outside rainstorm? Each has occurred in commerce in recent times and has caused line stoppages.

While there are no guarantees that continuous monitoring of package converting operations (especially in offshore locations) would have prevented these occurrences, one certainty is that the converters’ operators would have all been trained to watch for hazards and to remove them far upstream of the food/beverage packaging lines.

Kudos to the Packaging Association of Canada for developing a program that will become controversial, but in the end will be adopted and applied in package converting operations throughout North America.

by Aaron L. Brody, Ph.D.,
Contributing Editor
President and CEO, Packaging/Brody, Inc., Duluth, Ga., and Adjunct Professor, University of Georgia
[email protected]